Mattress Regulations in the United States: An Overview

Planning to manufacture or import mattresses in the United States? In this guide, we cover flammability standards, warning labels, chemicals, and heavy metals limits, lab testing options, and much more.

Mentioned Products

• Crib mattresses
• Bunk bed mattresses
• Convertible sofa bed mattresses
• Futons

Flammable Fabrics Act

The Flammable Fabrics Act (FFA) regulates the issue of flammability for textile products such as mattresses, garments, carpets, and fabric furniture, which are either manufactured in or imported to the United States. More specifically, the FFA lays down requirements for mattresses in CFR Part 1632 and Part 1633.

Examples of mattresses covered by Part 1632 and 1633

• Adult mattresses
• Youth mattresses
• Crib mattresses
• Bunk bed mattresses
• Convertible sofa bed mattresses
• Futons
• Water beds containing upholstery materials
• Air mattresses containing upholstery materials

16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads

16 CFR Part 1632 establishes flammability testing methods, and performance requirements for mattresses and mattress pads when exposed to smoldering ignition sources such as lighted cigarettes and matches. The objective of this standard is to diminish the risk of casualties arising from unforeseen mattresses and mattress pad fires.

Part 1632.4 specifies the test methods using cigarettes as the flaming source. It requires that the mattresses should be tested in a room with a temperature greater than 18 °C and relative humidity less than 55%.

The number of cigarettes used in this test varies from 3-18, depending on the existing mattress surface location of each individual mattress, i.e. smooth surface, tape edge, quilted, or tufted areas.

Labeling Requirements of 16 CFR Part 1632

16 CFR Part 1632.31 lays down labeling requirements for mattresses and mattress pads. Such products shall be labeled with at least the following content in a permanent conspicuous, and legible manner:

a. Instructions to protect the mattress from treatment that will deteriorate its ability to be flame resistant

b. The letter “T” indicates that the mattress contains chemical fire retardant (if it contains such substances)

16 CFR Part 1633 – Standard for the Flammability (Open Flame) of Mattress Sets

16 CFR Part 1633 is a flammability standard that establishes flammability requirements and testing procedures for mattress sets in order to decrease incidents and injuries caused by mattress fires.

Note that, according to the definition of 16 CFR Part 1633, a “Mattress Sets” refers to either a mattress and its foundation sold as a set, or a mattress that is sold without foundation.

This standard determines the flammability of the mattresses by testing the fire response characteristics of sample mattresses when exposed to specified flaming ignition sources in well-ventilated, controlled environmental conditions, and by observing their burning behaviors.

Labeling Requirements of 16 CFR Part 1633

16 CFR Part 1633.12 lays down labeling requirements for mattress sets. Such labels should be permanent, conspicuous, and legible, containing at least the following information in the English language:

a. Name and address of the manufacturer or importer

b. Date of manufacture

c. Model or Prototype identification number for the mattress set

d. A statement asserting that the mattress complies with 16 CFR Part 1633

You can find an example of such a label here.

General Certificate of Conformity

The Flammable Fabrics Act requires manufacturers and importers of mattresses to certify the safety and compliance of the products by self-issuing a General Certificate of Conformity (GCC).

The CPSC’s website provides a sample of GCC for mattresses, which shall include the following information:

a. Identification of the mattress (i.e. product name, model, etc.)

b. Citation to each CPSC safety standard for which the mattress is compliant (i.e. 16 CFR Part 1632, 16 CFR Part 1633)

c. Importer or manufacturer contact information (i.e. name, address, phone number, email address)

d. Contact information of the party who keeps records of test results (it can be either the importer or its representative)

e. Date and location of manufacturing and testing

f. Information about the CPSC-accredited laboratory that performed the tests

ASTM Safety Standards

ASTM has developed various standards regarding flammability, design, structural safety, accessory requirement, and others concerning the safety of mattresses in the US.

Unless stated otherwise by a specific regulation or act, such as CPSIA, ASTM standards are voluntary. However, the importer is still responsible for guaranteeing the safety of the products. Thus, it’s important to evaluate whether it might be necessary to test the product against one or more ASTM standards. This might be especially important in case no mandatory safety standards apply to the products.

ASTM E1590 – Standard Test Method for Fire Testing of Mattresses

ASTM E1590- sets test methods to determine the burning behavior of mattresses by measuring the heat release and smoke release when tested. The heat released from the burning mattress allows the testers to quantify the intensity of the fire generated.

This test method also measures other fire response characteristics of the mattresses, including the optical density of smoke, combustion gas release, and mass loss. These metrics are important for users to determine the fire safety level of mattresses.

This test method does not apply to smoldering ignition by cigarettes.

ASTM F2933 – Standard Consumer Safety Specification for Crib Mattresses

ASTM F2933 establishes requirements for the design, testing procedures, and labeling requirements for full-size crib mattresses, non-full-size crib mattresses, and mattresses for play yards.

This standard adopts the definition of “full-size crib” from 16 CFR 1219 and “non-full-size cribs” from 16 CFR 1220. Note that the dimension of a full-size crib is defined as:

• length = 1330±16mm
• width = 711±16mm

Referenced standards

This standard requires that any products that are under its scope shall comply with all other applicable mandatory federal statutes and regulations. In particular:

a. Mattress shall comply with the Flammable Fabric Act (16 CFR 1632 and 16 CFR 1633)

b. Mattresses shall have no small parts as defined by 16 CFR 1501.1500

c. Mattresses shall have no hazardous points or edges as defined by 16 CFR 1500.48 and 16 CFR 1500.49

d. Any paint and surface coatings on the mattress shall comply with 16 CFR 1303, which limits the concentration of lead to 90 parts per million (ppm)

This standard also references ASTM F2194 – Standard Consumer Safety Specification for Bassinets and Cradles, which includes specific test methods for these products, including a requirement for the flatness of segmented baby mattresses, in order to prevent the risks of asphyxiation.

Labeling and Warning Statement

ASTM F2933 lays down warning statement requirements, which shall be easy to read, legible, and permanent, and placed on the mattress and the packaging. The warning label shall include a word panel containing the safety alert symbol followed by the following suffocation hazard warning.

Note that you must buy the standard to find the relevant warning labels.

ASTM F1566 – Standard Test Methods for Evaluation of Innersprings, Boxsprings, Mattresses, or Mattress Sets

ASTM F1566 designs and compiles various sets of test methods to determine the firmness, firmness retention, durability, and effect of the impact of mattresses and their components such as innerspring, box springs, air chambers, foam cores, and foundations.

CPSIA: Children’s Mattresses

CPSIA is an act that regulates the safety of children’s products in the US. CPSIA adopts or refers to several ASTM standards for certain children’s products and articles.

ASTM Standards

ASTM partners with CPSC to develop mandatory and voluntary standards for manufacturers and importers of children’s products to comply with.

For mattresses that are intended to be used by children, the CPSC suggests the voluntary standard ASTM F2933 – Standard Consumer Safety Specification for Crib Mattresses, for manufacturers and importers of children’s mattresses to refer to.

Children’s Product Certificate (CPC)

A Children’s Product Certificate (CPC) is a document that states the safety and compliance of a children’s product, which is self-issued by the importer or manufacturer and required for any products under the scope of the CPSIA, including children’s mattresses.

The CPC should include the following information:

a. Mattress name and description

b. Applicable ASTM and CPSC standards (e.g ASTM F2933-19)

c. Importer company name, postal address, e-mail address, and phone number

d. Contact information of the party who maintains the test report

e. Manufacturing and testing date and location

f. Contact information of the CPSC accredited third-party lab testing company

CPSIA Tracking Label

Products covered by CPSIA, including mattresses, shall bear a CPSIA tracking label, which must be permanently affixed to the product or its packaging in order to facilitate the traceability of the product within the supply chain.

Example

• Mattress LLC
• Date of Manufacture: January 2021
• Date of Location: Hangzhou, China
• Batch number: KVC-224468-CHN
• All new materials
• Polyester

State Mattress Fire Safety Regulations

In this section, we introduce some state fire safety regulations that apply to mattresses

California TB 129 – Flammability Test Procedure for Mattresses for Use in Public Buildings

California TB 129 is a set of testing methods and standards to determine the burning behavior of mattresses used in public occupancies such as health care facilities, old age convalescent and board and care homes, college dormitories, and residence halls.

California TB 129 applies to finished mattresses and other complete bedding systems. This standard is not intended to test the individual component or materials used in the mattress, such as ticking materials, foams, and cotton battings.

BFD IX-11, Boston Fire Department Mattress Fire Test

BFD IX-11 is a fire test method developed by the Boston Fire Department to determine the flammability of upholstered products such as mattresses and beddings containing box springs used in health care facilities, hotels, and dormitories.

US Law Label

The US Law Label requires that the stuffed products that are used to support or rest should bear a label specifying the filling materials. More than 30 states enforce the Label Law currently, including California, New York, Illinois, Ohio, Texas, Virginia, and Arizona.

Products that are covered by this law include mattresses, pillows, sleeping bags, and other upholstered products.

Under the law, the label for a mattress shall include the following information:

• Company name of the importer
• Composition of the filling materials (Weight %)
• Uniform Registry Number (URN)
• A statement indicating that this label should not be removed: “Do Not Remove”

Country of Origin

In the United States, a label showing the Country of Origin must be permanently affixed to most consumer products, which include mattresses and mattress sets.

If a mattress is processed in more than a country, you shall carefully evaluate what country shall be stated in the Country of Origin label, as we explain in this article.

Lab Testing

To confirm the safety and compliance of mattresses with relevant standards and regulations, importers should consult professionals from lab testing companies that are experienced in the mattress industry.

Here are some lab testing companies that offer compliance services for mattresses manufactured or imported into the US:

• QIMA
• UL
• Intertek
• TÜV Rheinland
• Element